Data processing systems and methods for implementing audit schedules for privacy campaigns

ABSTRACT

Data processing systems and methods for retrieving data regarding a plurality of data privacy campaigns and for using that data to assess a relative risk associated with the data privacy campaign. In various embodiments, the system may be adapted to: (1) display one or more visual summaries of one or more data flow diagrams that visually depicts key features of the data flow, such as whether data is confidential and/or encrypted; (2) allow for multiple users to be assigned responsibility for populating different respective questions that are required to define the data flow; (3) automatically assess and display a relative risk associated with each campaign; and (4) automatically set, monitor, and facilitate the timely completion of an audit schedule for each campaign.

CROSS REFERENCE TO RELATED APPLICATIONS

This application is a continuation of U.S. patent application Ser. No.15/256,419, entitled “Data Processing Systems and Methods forOperationalizing Privacy Compliance and Assessing the Risk of VariousRespective Privacy Campaigns,” filed Sep. 2, 2016, which is acontinuation of U.S. patent application Ser. No. 15/169,643, entitled“Data Processing Systems and Methods for Operationalizing PrivacyCompliance and Assessing the Risk of Various Respective PrivacyCampaigns”, filed May 31, 2016, which claims the benefit of U.S.Provisional Application No. 62/317,457, entitled “Data ProcessingSystems and Methods for Operationalizing Privacy Compliance andAssessing the Risk of Various Respective Privacy Campaigns,” filed Apr.1, 2016, all of which are incorporated herein by reference in theirentirety.

TECHNICAL FIELD

This disclosure relates to a data processing system and methods forretrieving data regarding a plurality of privacy campaigns, and forusing that data to assess a relative risk associated with the dataprivacy campaign, provide an audit schedule for each campaign, andelectronically display campaign information.

BACKGROUND

Over the past years, privacy and security policies, and relatedoperations have become increasingly important. Breaches in security,leading to the unauthorized access of personal data (which may includesensitive personal data) have become more frequent among companies andother organizations of all sizes. Such personal data may include, but isnot limited to, personally identifiable information (PII), which may beinformation that directly (or indirectly) identifies an individual orentity. Examples of PII include names, addresses, dates of birth, socialsecurity numbers, and biometric identifiers such as a person'sfingerprints or picture. Other personal data may include, for example,customers' Internet browsing habits, purchase history, or even theirpreferences (i.e., likes and dislikes, as provided or obtained throughsocial media). While not all personal data may be sensitive, in thewrong hands, this kind of information may have a negative impact on theindividuals or entities whose sensitive personal data is collected,including identity theft and embarrassment. Not only would this breachhave the potential of exposing individuals to malicious wrongdoing, thefallout from such breaches may result in damage to reputation, potentialliability, and costly remedial action for the organizations thatcollected the information and that were under an obligation to maintainits confidentiality and security. These breaches may result in not onlyfinancial loss, but loss of credibility, confidence, and trust fromindividuals, stakeholders, and the public.

Many organizations that obtain, use, and transfer personal data,including sensitive personal data, have begun to address these privacyand security issues. To manage personal data, many companies haveattempted to implement operational policies and processes that complywith legal requirements, such as Canada's Personal InformationProtection and Electronic Documents Act (PIPEDA) or the U.S.'s HealthInsurance Portability and Accountability Act (HIPPA) protecting apatient's medical information. The European Union's General DataProtection Regulation (GDPR) can fine companies up to 4% of their globalworldwide turnover (revenue) for not complying with its regulations(companies must comply by March 2018). These operational policies andprocesses also strive to comply with industry best practices (e.g., theDigital Advertising Alliance's Self-Regulatory Principles for OnlineBehavioral Advertising). Many regulators recommend conducting privacyimpact assessments, or data protection risk assessments along with datainventory mapping. For example, the GDPR requires data protection impactassessments. Additionally, the United Kingdom ICO's office providesguidance around privacy impact assessments. The OPC in Canada recommendspersonal information inventory, and the Singapore PDPA specificallymentions personal data inventory mapping.

Thus, developing operational policies and processes may reassure notonly regulators, but also an organization's customers, vendors, andother business partners.

For many companies handling personal data, privacy audits, whether doneaccording to AICPA Generally Accepted Privacy Principles, or ISACA's ITStandards, Guidelines, and Tools and Techniques for Audit Assurance andControl Professionals, are not just a best practice, they are arequirement (for example, Facebook and Google will be required toperform 10 privacy audits each until 2032 to ensure that their treatmentof personal data comports with the expectations of the Federal TradeCommission). When the time comes to perform a privacy audit, be it acompliance audit or adequacy audit, the lack of transparency or clarityinto where personal data comes from, where is it stored, who is usingit, where it has been transferred, and for what purpose is it beingused, may bog down any privacy audit process. Even worse, after a breachoccurs and is discovered, many organizations are unable to even identifya clear-cut organizational owner responsible for the breach recovery, orprovide sufficient evidence that privacy policies and regulations werecomplied with.

In light of the above, there is currently a need for improved systemsand methods for monitoring compliance with corporate privacy policiesand applicable privacy laws.

SUMMARY

According to exemplary embodiments, a system for operationalizingprivacy compliance is described herein. The system may be comprised ofone or more servers and client computing devices that execute one ormore software modules that perform functions and methods related to theinput, processing, storage, retrieval, and display of campaign datarelated to a privacy campaign. A privacy campaign may be any businessfunction, system, product, technology, process, project, engagement,initiative, campaign, etc., that may utilize personal data collectedfrom one or more persons or entities. Campaign data may datarepresentative of one or more attributes related to the personal datacollected as part of the campaign.

A computer-implemented data processing system and method is operable forelectronically receiving the input of campaign data associated with aprivacy campaign, and electronically calculating a risk level for theprivacy campaign based on the campaign data.

The system is operable for displaying on a graphical user interface(GUI) a prompt to create an electronic record for a privacy campaign.The system receives a command to create an electronic record for theprivacy campaign, creates an electronic record for the privacy campaignand digitally stores the record. The system presents on one or moregraphical user interfaces a plurality of prompts for the input ofcampaign data related to the privacy campaign. It electronicallyreceives any campaign data input by one or more users. The privacycampaign data may relate to a description of the campaign, one or moretypes of personal data related to the campaign, a subject from which thepersonal data was collected, the storage of the personal data, andaccess to the personal data.

The system processes the campaign data by electronically associating thecampaign data with the record for the privacy campaign, and digitallystoring the campaign data associated with the record for the campaign.

Using a microprocessor, the system calculates a “Risk Level” for thecampaign based on the campaign data, electronically associates the risklevel with the record for the campaign; and digitally stores the risklevel associated with the record for the campaign (e.g., in a storagedevice such as a networked hard drive, a cloud drive, the hard drive ofone or more computing devices, etc.).

The users of the system may be an owner of the campaign, who may be aprivacy officer (i.e., personnel working in an organization under theChief Privacy Officer). The privacy officer may input an initial portionof the campaign data, such as the name of the campaign, the descriptionof the campaign, and the business group responsible for administeringthe privacy operations related to that campaign.

The system is also operable for accepting an input to add one or morecollaborators designated by one or more users (who may be an owner) toinput campaign data. Once a user designates a collaborator, who may beanother owner or a business office representative, the system sends anelectronic message to the collaborator regarding the addition of thecollaborator for adding campaign data for the privacy campaign (e.g.,letting the collaborator know that he has been added to the campaign,providing him with system login details, responsibilities, and deadlinesfor providing his portion of the campaign data). The collaborator may bedesignated to input different portions of the campaign data. Thecollaborator may be designated to provide input for one or more prompts,including one or more questions. The collaborator may be designated toprovide input for part of a question.

The system is operable for accepting one or more inputs of campaign datafrom the users, who may be owners or collaborator(s), and for anycampaign data that has been added, the system electronically associatesthe campaign data received from the input of the users with the recordof the campaign, and digitally stores the campaign data received fromthe input of the collaborator with the record for the campaign (again,this may also be in a storage device such as a networked hard drive, acloud drive, the hard drive of one or more computing devices, etc.).

The system can collect this campaign data by presenting a plurality ofprompts for inputting the campaign data to the users (who may be aprivacy officer, a business rep, or other collaborators). The promptsmay be presented through a series of computer-generated GUIs (forexample, webpages), wherein each GUI displays one or more of the promptsfor campaign data, and wherein each GUI page is presented one at a time(e.g., in a screen by screen manner, for example, in five phases asshown in FIGS. 8 through 14). One or more graphical user interface pagesmay be an online form comprising one or more fields in which a user caninput data. The graphical user interface may have a visually displayedshape (such as a circle) that can be filled by the user to input data.The graphical user interface may have a drop-down menu from which a usercan select an item.

Also, to facilitate collaboration, a computer implemented method may beoperable for instantiating a real-time communication session overlayinga portion of a user interface. One or more GUI pages having prompts maydisplay an indicator (e.g., the “comment button” shown in FIGS. 9through 13), wherein if the indicator is selected, it retrieves a listof one or more collaborators associated with at least one record relatedto the information displayed on the online graphical user interface,wherein the list of collaborators includes the user and at least oneother person. The system then electronically instantiates a real-timecommunication session (e.g., an instant messaging session, a chatsession, etc.) between the user and the one or more collaborators in acomputer-generated window, wherein the window having the real-timecommunications session overlays the online graphical user interface,covering at least a portion of the graphical user interface.

When the user responds to the prompts and enters inputs (for example,through fields, drop down menus, check boxes, radial selections), thesystem may be operable to automatically populate one or more fieldsbased on the data input history of the user. The system may also beoperable to automatically populate one or more fields for the entry ofdata inputs based on the type of campaign data entered from a previousinput (e.g., if the input is related to personal data, the check boxescommonly used for personal data can be automatically checked. See, e.g.,FIG. 10). Based on the input of campaign data received from the one ormore users, the system can present further prompts related to thecampaign data that was input (e.g., if a user selects a box thatindicates that the personal information being collected includespersonal data, the user can be presented with another dialog with moreselections related to personal data. See, e.g., FIG. 10).

The system is also operable for sending reminders. If required campaigndata has not been received, the system sends one or more electronicnotifications that indicates that required campaign data has not yetbeen provided, thereby facilitating the gathering of different portionsof information from one or more collaborators until all the requiredcampaign data for a privacy campaign has been input.

The system is operable to use the campaign data input into the system tocalculate a “Risk Level”. The system electronically retrieves from adatabase the campaign data associated with the record for the campaign,electronically determines a plurality of “weighting factors” for thecampaign, wherein the plurality of weighting factors are based upon anumber of factors including the nature of the personal data associatedwith the campaign, the physical location of the personal data associatedwith the campaign, the number of individuals having access to thepersonal data associated with the campaign, the length of time that thepersonal data associated with the campaign will be retained in storage,the type of individual from which the personal data associated with thecampaign originated, and the country of residence of the individual fromwhich the personal data associated with the campaign originated. Eachweighting factor is electronically assigned a higher numerical value ifthe risk associated with the factor is higher.

In addition to the determining the weighting factors, the systemelectronically assigns a “relative risk rating” for each of theplurality of factors. Based on weighting factors and the relative riskrating for each of the plurality of factors, the system electronicallycalculates a risk level for the campaign. The system may use analgorithm to make this calculation, for example, the Risk Level may beelectronically calculated as the sum of a plurality of: a weightingfactor multiplied by the relative risk rating of the factor (i.e., RiskLevel for campaign=(Weighting Factor of Factor 1)*(Relative Risk Ratingof Factor 1)+(Weighting Factor of Factor 2)*(Relative Risk Rating ofFactor 2)+ . . . (Weighting Factor of Factor N)*(Relative Risk Rating ofFactor N).

The system may also determine an Overall Risk Assessment for thecampaign and digitally store the Overall Risk Assessment with the recordfor the campaign, and wherein the Overall Risk Assessment is determinedbased upon a plurality of numerical ranges of risk levels (e.g., acampaign having a Risk Level of 1-7 is “low risk,” (2) campaigns with aRisk Level of 8-15 are “medium risk,” and (3) campaigns with a RiskLevel of over 16 as “high risk”).

The system may also be operable to electronically retrieve the campaignrecord and the campaign data associated with the record, and generatingfor display a computer-generated user interface comprising an inventorypage (e.g., the inventory page shown in FIG. 15). The inventory page maydisplay a list of a plurality of campaigns, and visual indicators thatrelate to the risk level for each listed campaign. The visual indicatorsmay represent an overall risk assessment for the campaign. The visualindicators may be an upward pointing arrow, a downward pointing arrow,or different colors for each overall risk assessment level. On theinventory page, the plurality of campaigns can be sorted based on risk.

The system, when displaying any information, including information onthe inventory page, can display information based on the permissionsassigned to each user. The system may receive a login from the user, andbased upon the identity of the user, determining which campaign-relateddata the one or more users is authorized to view. The system retrievesand displays only the campaign data that the user is authorized to view(for example, on the inventory page, a user that is a business rep maynot be able to see every campaign, but only the campaigns that he or sheis assigned to).

A computer-implemented data processing system and method is operable forassigning a schedule for a privacy audit associated with a privacycampaign. The system is operable for displaying on a graphical userinterface a prompt to create an electronic record for a privacycampaign, receiving a command to create an electronic record for theprivacy campaign, creating an electronic record for the privacy campaignand digitally storing the record, presenting on one or more graphicaluser interfaces a plurality of prompts for the input of campaign datarelated to the privacy campaign, and electronically receiving campaigndata input by one or more users. The campaign data may relate to adescription of the campaign, one or more types of personal data relatedto the campaign, a subject from which the personal data was collected,the storage of the personal data, and access to the personal data. Thesystem processes the campaign data by electronically associating thecampaign data with the record for the privacy campaign, digitallystoring the campaign data associated with the record for the campaign,and assigning a privacy audit schedule for the campaign based on therisk associated with the campaign (which may be the risk level for thecampaign, or the overall risk assessment for the campaign), wherein theaudit schedule comprises a timeframe until the scheduled privacy audit.The audit schedule may be a default audit schedule predetermined for therisk associated with the campaign. The default audit schedule, which canbe modifiable, may be based on privacy laws, company policies, or thelike.

After the audit schedule for the campaign has been assigned, it may bemodified. The system may be operable to receive an input to modify theaudit schedule assigned to the campaign and determine whether the auditschedule assigned to the campaign is modifiable (e.g., modifiable by auser of the system). If the audit schedule assigned to the campaign ismodifiable, the system modifies the audit schedule for the campaign. Ifthe audit schedule is not modifiable, electronically displaying anindication that the audit schedule is not modifiable, a user can send arequest to modify the audit schedule. The system receives the request tomodify the audit schedule for the campaign, and may send an electronicmessage to persons having the authority to grant permission to modifythe audit schedule, thereby letting them know that a request to modifythe audit schedule is pending.

The system can determine whether a threshold amount of time until theprivacy audit has been reached, and if the threshold has been reached,generate an electronic alert indicating that the privacy audit deadlineis in the threshold amount of time (e.g., generating an alert that thereis 90 days until the privacy audit deadline, if 90 days is onethreshold). If the system receives an electronic confirmation that thescheduled privacy audit has been completed, it resets the auditschedule's timeframe until the next privacy audit. The electronicconfirmation may be an electronic verification generated when allportions of the audit have been verified as completed by one or morecollaborators. The system may further operable for receivingdocumentation related to the compliance of the privacy campaign,electronically associating the documentation received with the record ofthe campaign, and digitally storing the documentation associated withthe record for the campaign in an electronic storage device (e.g., in astorage device such as a networked hard drive, a cloud drive, the harddrive of one or more computing devices, etc.).

The system may be operable to facilitate the auditing and complianceprocess by determining if the scheduled privacy audit is overdue basedon whether an electronic confirmation that the scheduled privacy audithas been completed has been received. If the scheduled privacy audit isoverdue, the system may generate an electronic alert indicating that theprivacy audit is overdue.

The system can also display audit related information to the user byelectronically retrieving the campaign record and the campaign dataassociated with the record (including audit information), and generatingfor display a computer-generated user interface comprising an inventorypage, wherein the inventory page displays a list of a plurality ofcampaigns and audit information, which may be based upon the auditschedule, for one or more of the plurality of campaigns. The auditinformation displayed may show whether an audit associated with thecampaign is pending, complete, or due, and indicate the number of daysbefore the audit is to be conducted (see, e.g., FIG. 15).

A computer-implemented data processing method is operable for generatinga data flow diagram for a privacy campaign. The system is operable fordisplaying on a graphical user interface a prompt to create anelectronic record for a privacy campaign, receiving a command to createan electronic record for the privacy campaign, creating an electronicrecord for the privacy campaign and digitally storing the record,presenting on one or more graphical user interfaces a plurality ofprompts for the input of campaign data, and electronically receivingcampaign data input by one or more users. The campaign data may relateto a description of the campaign, one or more types of personal datarelated to the campaign, a subject from which the personal data wascollected, the storage of the personal data, and access to the personaldata. The system processes the campaign data by electronicallyassociating the campaign data with the record for the privacy campaign,and generating for display a data flow diagram on a computer-generatedgraphical user interface, wherein the data flow diagram comprisesindicators related to the accessibility and encryption of the personaldata related to the campaign.

The data flow diagram may display a heading indicative of the source ofthe personal data, the storage destination of the personal data, andaccess related to the personal data. The system is operable to generateone or more on on-screen objects shown in the data flow diagram, whereineach object contains a hyperlink label indicative of the source of thepersonal data, the storage destination of the personal data, and accessrelated to the personal data, wherein additional campaign data relatingto the campaign data associated with the hyperlinked word is displayedif a cursor is moved over the hyperlink label (e.g., on FIG. 16, theobjects are rectangular boxes, the boxes containing the hyperlinked textCustomers, Internet Usage, Customer Support, and Billing System).

Based on the campaign data associated with the campaign, the system maydetermine whether the personal data related to each of the hyperlinklabels is confidential. If the personal data is confidential, the systemgenerates an indicator indicating that the data associated with thehyperlink label is confidential, such as an “open eye” icon as show inFIG. 16. The system may also generate for display information relatingto whether the source of the personal data includes minors, and generatefor display an indication of whether consent was given by the source ofthe personal data to use any sensitive information, as well as themanner in which the consent was given (e.g., through an end user licenseagreement EULA). The system may also display on the data flow diagramone or more parameters related to the backup and retention of thepersonal data in the storage destination of the personal data.

The system may also generate on the data flow diagram data flow lineshaving arrows to indicate the data flow of personal data from source, tostorage destination, to which entities or applications have access. Ifthe system determines whether any of the data associated with thesource, stored in a storage destination, being used by an entity orapplication, or data flow of data flowing to one or more entities orsystems associated with the campaign is designated as encrypted, it cangenerate indicators on the data flow diagram. The system may generate alocked lock icon to indicate encrypted data, and generate an unlockedlock icon to indicate unencrypted data. The system may generate a lockedlock icon to indicate encrypted data flow, and may generate an unlockedlock icon to indicate unencrypted data flow. The data flow lines may becolored differently to indicate whether the data flow is encrypted orunencrypted, and those colors may be distinguishable by a viewer thatsuffers from color blindness.

BRIEF DESCRIPTION OF THE DRAWINGS

Various embodiments of a system and method for operationalizing privacycompliance and assessing risk of privacy campaigns are described below.In the course of this description, reference will be made to theaccompanying drawings, which are not necessarily drawn to scale, andwherein:

FIG. 1 is diagram illustrating an exemplary network environment in whichthe present system and methods for operationalizing privacy compliancemay operate.

FIG. 2 is a schematic diagram of a computer (such as the server 120, oruser device 140, 150, 160, 170, 180, 190) that is suitable for use invarious embodiments.

FIG. 3 is a diagram illustrating an example of the elements (e.g.,subjects, owner, etc.) that may be involved in privacy compliance.

FIG. 4 is a flow chart showing an example of a process performed by theMain Privacy Compliance Module.

FIG. 5 is a flow chart showing an example of a process performed by theRisk Assessment Module.

FIG. 6 is a flow chart showing an example of a process performed by thePrivacy Audit Module.

FIG. 7 is a flow chart showing an example of a process performed by theData Flow Diagram Module.

FIG. 8 is an example of a Graphical User Interface (GUI) showing adialog that allows for entry of description information related to aprivacy campaign.

FIG. 9 shows example of a notification to a business representative(i.e., owner) related to his/her assignment of a privacy campaign.

FIG. 10 is an example of a GUI showing a dialog allowing entry of thetype of personal data that is being collected for a privacy campaign.

FIG. 11 is an example of a GUI that shows a dialog that allowscollection of campaign data regarding the subject from whom the personaldata was collected.

FIG. 12 is an example of a GUI that shows a dialog for inputtinginformation regarding where the personal data related to a campaign isstored.

FIG. 13 is an example of a GUI that shows information regarding theaccess of the personal data related to a campaign.

FIG. 14 is an example of an instant messaging session overlaid on top ofa GUI, wherein the GUI contains prompts for the entry or selection ofcampaign data.

FIG. 15 is an example of a GUI showing an inventory page.

FIG. 16 is an example of a GUI showing campaign data, including a dataflow diagram.

FIG. 17 is an example of a GUI showing a page that allows editing ofcampaign data.

DETAILED DESCRIPTION

Various embodiments now will be described more fully hereinafter withreference to the accompanying drawings. It should be understood that theinvention may be embodied in many different forms and should not beconstrued as limited to the embodiments set forth herein. Rather, theseembodiments are provided so that this disclosure will be thorough andcomplete, and will fully convey the scope of the invention to thoseskilled in the art. Like numbers refer to like elements throughout.

Overview

According to exemplary embodiments, a system for operationalizingprivacy compliance is described herein. The system may be comprised ofone or more servers and client computing devices that execute softwaremodules that facilitate various functions.

A Main Privacy Compliance Module is operable to allow a user to initiatethe creation of a privacy campaign (i.e., a business function, system,product, technology, process, project, engagement, initiative, campaign,etc., that may utilize personal data collected from one or more personsor entities). The personal data may contain PII that may be sensitivepersonal data. The user can input information such as the name anddescription of the campaign. The user may also select whether he/shewill take ownership of the campaign (i.e., be responsible for providingthe information needed to create the campaign and oversee the conductingof privacy audits related to the campaign), or assign the campaign toone or more other persons. The Main Privacy Compliance Module cangenerate a sequence or serious of GUI windows that facilitate the entryof campaign data representative of attributes related to the privacycampaign (e.g., attributes that might relate to the description of thepersonal data, what personal data is collected, whom the data iscollected from, the storage of the data, and access to that data).

Based on the information input, a Risk Assessment Module may be operableto take into account Weighting Factors and Relative Risk Ratingsassociated with the campaign in order to calculate a numerical RiskLevel associated with the campaign, as well as an Overall RiskAssessment for the campaign (i.e., low-risk, medium risk, or high risk).The Risk Level may be indicative of the likelihood of a breach involvingpersonal data related to the campaign being compromised (i.e., lost,stolen, accessed without authorization, inadvertently disclosed,maliciously disclosed, etc.). An inventory page can visually depict theRisk Level for one or more privacy campaigns.

After the Risk Assessment Module has determined a Risk Level for acampaign, a Privacy Audit Module may be operable to use the Risk Levelto determine an audit schedule for the campaign. The audit schedule maybe editable, and the Privacy Audit Module also facilitates the privacyaudit process by sending alerts when a privacy audit is impending, orsending alerts when a privacy audit is overdue.

The system may also include a Data Flow Diagram Module for generating adata flow diagram associated with a campaign. An exemplary data flowdiagram displays one or more shapes representing the source from whichdata associated with the campaign is derived, the destination (orlocation) of that data, and which departments or software systems mayhave access to the data. The Data Flow Diagram Module may also generateone or more security indicators for display. The indicators may include,for example, an “eye” icon to indicate that the data is confidential, a“lock” icon to indicate that the data, and/or a particular flow of data,is encrypted, or an “unlocked lock” icon to indicate that the data,and/or a particular flow of data, is not encrypted. Data flow lines maybe colored differently to indicate whether the data flow is encrypted orunencrypted.

The system also provides for a Communications Module that facilitatesthe creation and transmission of notifications and alerts (e.g., viaemail). The Communications Module may also instantiate an instantmessaging session and overlay the instant messaging session over one ormore portions of a GUI in which a user is presented with prompts toenter or select information.

Exemplary Technical Platforms

As will be appreciated by one skilled in the relevant field, a systemfor operationalizing privacy compliance and assessing risk of privacycampaigns may be, for example, embodied as a computer system, a method,or a computer program product. Accordingly, various embodiments may takethe form of an entirely hardware embodiment, an entirely softwareembodiment, or an embodiment combining software and hardware aspects.Furthermore, particular embodiments may take the form of a computerprogram product stored on a computer-readable storage medium havingcomputer-readable instructions (e.g., software) embodied in the storagemedium. Various embodiments may take the form of web, mobile, wearablecomputer-implemented, computer software. Any suitable computer-readablestorage medium may be utilized including, for example, hard disks,compact disks, DVDs, optical storage devices, and/or magnetic storagedevices.

Various embodiments are described below with reference to block diagramsand flowchart illustrations of methods, apparatuses (e.g., systems) andcomputer program products. It should be understood that each step of theblock diagrams and flowchart illustrations, and combinations of steps inthe block diagrams and flowchart illustrations, respectively, may beimplemented by a computer executing computer program instructions. Thesecomputer program instructions may be loaded onto a general purposecomputer, special purpose computer, or other programmable dataprocessing apparatus to produce a machine, such that the instructionswhich execute on the computer or other programmable data processingapparatus to create means for implementing the functions specified inthe flowchart step or steps

These computer program instructions may also be stored in acomputer-readable memory that may direct a computer or otherprogrammable data processing apparatus to function in a particularmanner such that the instructions stored in the computer-readable memoryproduce an article of manufacture that is configured for implementingthe function specified in the flowchart step or steps. The computerprogram instructions may also be loaded onto a computer or otherprogrammable data processing apparatus to cause a series of operationalsteps to be performed on the computer or other programmable apparatus toproduce a computer implemented process such that the instructions thatexecute on the computer or other programmable apparatus provide stepsfor implementing the functions specified in the flowchart step or steps.

Accordingly, steps of the block diagrams and flowchart illustrationssupport combinations of mechanisms for performing the specifiedfunctions, combinations of steps for performing the specified functions,and program instructions for performing the specified functions. Itshould also be understood that each step of the block diagrams andflowchart illustrations, and combinations of steps in the block diagramsand flowchart illustrations, may be implemented by special purposehardware-based computer systems that perform the specified functions orsteps, or combinations of special purpose hardware and other hardwareexecuting appropriate computer instructions.

Example System Architecture

FIG. 1 is a block diagram of a System 100 according to a particularembodiment. As may be understood from this figure, the System 100includes one or more computer networks 110, a Server 120, a StorageDevice 130 (which may contain one or more databases of information), oneor more remote client computing devices such as a tablet computer 140, adesktop or laptop computer 150, or a handheld computing device 160, suchas a cellular phone, browser and Internet capable set-top boxes 170connected with a TV 180, or even smart TVs 180 having browser andInternet capability. The client computing devices attached to thenetwork may also include copiers/printers 190 having hard drives (asecurity risk since copies/prints may be stored on these hard drives).The Server 120, client computing devices, and Storage Device 130 may bephysically located in a central location, such as the headquarters ofthe organization, for example, or in separate facilities. The devicesmay be owned or maintained by employees, contractors, or other thirdparties (e.g., a cloud service provider). In particular embodiments, theone or more computer networks 115 facilitate communication between theServer 120, one or more client computing devices 140, 150, 160, 170,180, 190, and Storage Device 130.

The one or more computer networks 115 may include any of a variety oftypes of wired or wireless computer networks such as the Internet, aprivate intranet, a public switched telephone network (PSTN), or anyother type of network. The communication link between the Server 120,one or more client computing devices 140, 150, 160, 170, 180, 190, andStorage Device 130 may be, for example, implemented via a Local AreaNetwork (LAN) or via the Internet.

Example Computer Architecture Used within the System

FIG. 2 illustrates a diagrammatic representation of the architecture ofa computer 200 that may be used within the System 100, for example, as aclient computer (e.g., one of computing devices 140, 150, 160, 170, 180,190, shown in FIG. 1), or as a server computer (e.g., Server 120 shownin FIG. 1). In exemplary embodiments, the computer 200 may be suitablefor use as a computer within the context of the System 100 that isconfigured to operationalize privacy compliance and assess risk ofprivacy campaigns. In particular embodiments, the computer 200 may beconnected (e.g., networked) to other computers in a LAN, an intranet, anextranet, and/or the Internet. As noted above, the computer 200 mayoperate in the capacity of a server or a client computer in aclient-server network environment, or as a peer computer in apeer-to-peer (or distributed) network environment. The computer 200 maybe a personal computer (PC), a tablet PC, a set-top box (STB), aPersonal Digital Assistant (PDA), a cellular telephone, a web appliance,a server, a network router, a switch or bridge, or any other computercapable of executing a set of instructions (sequential or otherwise)that specify actions to be taken by that computer. Further, while only asingle computer is illustrated, the term “computer” shall also be takento include any collection of computers that individually or jointlyexecute a set (or multiple sets) of instructions to perform any one ormore of the methodologies discussed herein.

An exemplary computer 200 includes a processing device 202, a mainmemory 204 (e.g., read-only memory (ROM), flash memory, dynamic randomaccess memory (DRAM) such as synchronous DRAM (SDRAM) or Rambus DRAM(RDRAM), etc.), a static memory 206 (e.g., flash memory, static randomaccess memory (SRAM), etc.), and a data storage device 218, whichcommunicate with each other via a bus 232.

The processing device 202 represents one or more general-purposeprocessing devices such as a microprocessor, a central processing unit,or the like. More particularly, the processing device 202 may be acomplex instruction set computing (CISC) microprocessor, reducedinstruction set computing (RISC) microprocessor, very long instructionword (VLIW) microprocessor, or processor implementing other instructionsets, or processors implementing a combination of instruction sets. Theprocessing device 202 may also be one or more special-purpose processingdevices such as an application specific integrated circuit (ASIC), afield programmable gate array (FPGA), a digital signal processor (DSP),network processor, or the like. The processing device 202 may beconfigured to execute processing logic 226 for performing variousoperations and steps discussed herein.

The computer 200 may further include a network interface device 208. Thecomputer 200 also may include a video display unit 210 (e.g., a liquidcrystal display (LCD) or a cathode ray tube (CRT)), an alphanumericinput device 212 (e.g., a keyboard), a cursor control device 214 (e.g.,a mouse), and a signal generation device 216 (e.g., a speaker). The datastorage device 218 may include a non-transitory computer-readablestorage medium 230 (also known as a non-transitory computer-readablestorage medium or a non-transitory computer-readable medium) on which isstored one or more sets of instructions 222 (e.g., software, softwaremodules) embodying any one or more of the methodologies or functionsdescribed herein. The software 222 may also reside, completely or atleast partially, within main memory 204 and/or within processing device202 during execution thereof by computer 200—main memory 204 andprocessing device 202 also constituting computer-accessible storagemedia. The software 222 may further be transmitted or received over anetwork 220 via network interface device 208.

While the computer-readable storage medium 230 is shown in an exemplaryembodiment to be a single medium, the terms “computer-readable storagemedium” and “machine-accessible storage medium” should be understood toinclude a single medium or multiple media (e.g., a centralized ordistributed database, and/or associated caches and servers) that storethe one or more sets of instructions. The term “computer-readablestorage medium” should also be understood to include any medium that iscapable of storing, encoding or carrying a set of instructions forexecution by the computer and that cause the computer to perform any oneor more of the methodologies of the present invention. The term“computer-readable storage medium” should accordingly be understood toinclude, but not be limited to, solid-state memories, optical andmagnetic media, etc.

Exemplary System Platform

According to various embodiments, the processes and logic flowsdescribed in this specification may be performed by a system (e.g.,System 100) that includes, but is not limited to, one or moreprogrammable processors (e.g., processor 202) executing one or morecomputer program modules to perform functions by operating on input dataand generating output, thereby tying the process to a particular machine(e.g., a machine programmed to perform the processes described herein).This includes processors located in one or more of client computers(e.g., client computers 140, 150, 160, 170, 180, 190 of FIG. 1). Thesedevices connected to network 110 may access and execute one or moreInternet browser-based program modules that are “served up” through thenetwork 110 by one or more servers (e.g., server 120 of FIG. 1), and thedata associated with the program may be stored on a one or more storagedevices, which may reside within a server or computing device (e.g.,Main Memory 204, Static Memory 206), be attached as a peripheral storagedevice to the one or more servers or computing devices, or attached tothe network (e.g., Storage 130).

The System 100 facilitates the acquisition, storage, maintenance, use,and retention of campaign data associated with a plurality of privacycampaigns within an organization. In doing so, various aspects of theSystem 100 initiates and creates a plurality of individual data privacycampaign records that are associated with a variety of privacy-relatedattributes and assessment related meta-data for each campaign. Thesedata elements may include: the subjects of the sensitive information,the respective person or entity responsible for each campaign (e.g., thecampaign's “owner”), the location where the personal data will bestored, the entity or entities that will access the data, the parametersaccording to which the personal data will be used and retained, the RiskLevel associated with a particular campaign (as well as assessments fromwhich the Risk Level is calculated), an audit schedule, and otherattributes and meta-data. The System 100 may also be adapted tofacilitate the setup and auditing of each privacy campaign. Thesemodules may include, for example, a Main Privacy Compliance Module, aRisk Assessment Module, a Privacy Audit Module, a Data Flow DiagramModule, and a Communications Module (examples of which are describedbelow). It is to be understood that these are examples of modules ofvarious embodiments, but the functionalities performed by each module asdescribed may be performed by more (or less) modules. Further, thefunctionalities described as being performed by one module may beperformed by one or more other modules.

A. Example Elements Related to Privacy Campaigns

FIG. 3 provides a high-level visual overview of example “subjects” forparticular data privacy campaigns, exemplary campaign “owners,” variouselements related to the storage and access of personal data, andelements related to the use and retention of the personal data. Each ofthese elements may, in various embodiments, be accounted for by theSystem 100 as it facilitates the implementation of an organization'sprivacy compliance policy.

As may be understood from FIG. 3, sensitive information may be collectedby an organization from one or more subjects 300. Subjects may includecustomers whose information has been obtained by the organization. Forexample, if the organization is selling goods to a customer, theorganization may have been provided with a customer's credit card orbanking information (e.g., account number, bank routing number), socialsecurity number, or other sensitive information.

An organization may also possess personal data originating from one ormore of its business partners. Examples of business partners are vendorsthat may be data controllers or data processors (which have differentlegal obligations under EU data protection laws). Vendors may supply acomponent or raw material to the organization, or an outside contractorresponsible for the marketing or legal work of the organization. Thepersonal data acquired from the partner may be that of the partners, oreven that of other entities collected by the partners. For example, amarketing agency may collect personal data on behalf of theorganization, and transfer that information to the organization.Moreover, the organization may share personal data with one of itspartners. For example, the organization may provide a marketing agencywith the personal data of its customers so that it may conduct furtherresearch.

Other subjects 300 include the organization's own employees.Organizations with employees often collect personal data from theiremployees, including address and social security information, usuallyfor payroll purposes, or even prior to employment, for conducting creditchecks. The subjects 300 may also include minors. It is noted thatvarious corporate privacy policies or privacy laws may require thatorganizations take additional steps to protect the sensitive privacy ofminors.

Still referring to FIG. 3, within an organization, a particularindividual (or groups of individuals) may be designated to be an “owner”of a particular campaign to obtain and manage personal data. Theseowners 310 may have any suitable role within the organization. Invarious embodiments, an owner of a particular campaign will have primaryresponsibility for the campaign, and will serve as a resident expertregarding the personal data obtained through the campaign, and the waythat the data is obtained, stored, and accessed. As shown in FIG. 3, anowner may be a member of any suitable department, including theorganization's marketing, HR, R&D, or IT department. As will bedescribed below, in exemplary embodiments, the owner can always bechanged, and owners can sub-assign other owners (and othercollaborators) to individual sections of campaign data input andoperations.

Referring still to FIG. 3, the system may be configured to account forthe use and retention 315 of personal data obtained in each particularcampaign. The use and retention of personal data may include how thedata is analyzed and used within the organization's operations, whetherthe data is backed up, and which parties within the organization aresupporting the campaign.

The system may also be configured to help manage the storage and access320 of personal data. As shown in FIG. 3, a variety of different partiesmay access the data, and the data may be stored in any of a variety ofdifferent locations, including on-site, or in “the cloud”, i.e., onremote servers that are accessed via the Internet or other suitablenetwork.

B. Main Compliance Module

FIG. 4 illustrates an exemplary process for operationalizing privacycompliance. Main Privacy Compliance Module 400, which may be executed byone or more computing devices of System 100, may perform this process.In exemplary embodiments, a server (e.g., server 140) in conjunctionwith a client computing device having a browser, execute the MainPrivacy Compliance Module (e.g., computing devices 140, 150, 160, 170,180, 190) through a network (network 110). In various exemplaryembodiments, the Main Privacy Compliance Module 400 may call upon othermodules to perform certain functions. In exemplary embodiments, thesoftware may also be organized as a single module to perform variouscomputer executable routines.

I. Adding a Campaign

The process 400 may begin at step 405, wherein the Main PrivacyCompliance Module 400 of the System 100 receives a command to add aprivacy campaign. In exemplary embodiments, the user selects anon-screen button (e.g., the Add Data Flow button 1555 of FIG. 15) thatthe Main Privacy Compliance Module 400 displays on a landing page, whichmay be displayed in a graphical user interface (GUI), such as a window,dialog box, or the like. The landing page may be, for example, theinventory page 1500 below. The inventory page 1500 may display a list ofone or more privacy campaigns that have already been input into theSystem 100. As mentioned above, a privacy campaign may represent, forexample, a business operation that the organization is engaged in, orsome business record, that may require the use of personal data, whichmay include the personal data of a customer or some other entity.Examples of campaigns might include, for example, Internet UsageHistory, Customer Payment Information, Call History Log, CellularRoaming Records, etc. For the campaign “Internet Usage History,” amarketing department may need customers' on-line browsing patterns torun analytics. This might entail retrieving and storing customers' IPaddresses, MAC address, URL history, subscriber ID, and otherinformation that may be considered personal data (and even sensitivepersonal data). As will be described herein, the System 100, through theuse of one or more modules, including the Main Privacy Campaign Module400, creates a record for each campaign. Data elements of campaign datamay be associated with each campaign record that represents attributessuch as: the type of personal data associated with the campaign; thesubjects having access to the personal data; the person or personswithin the company that take ownership (e.g., business owner) forensuring privacy compliance for the personal data associated with eachcampaign; the location of the personal data; the entities having accessto the data; the various computer systems and software applications thatuse the personal data; and the Risk Level (see below) associated withthe campaign.

II. Entry of Privacy Campaign Related Information, Including Owner

At Step 410, in Response to the Receipt of the User's Command to Add aPrivacy campaign record, the Main Privacy Compliance Module 400initiates a routine to create an electronic record for a privacycampaign, and a routine for the entry data inputs of information relatedto the privacy campaign. The Main Privacy Compliance Module 400 maygenerate one or more graphical user interfaces (e.g., windows, dialogpages, etc.), which may be presented one GUI at a time. Each GUI mayshow prompts, editable entry fields, check boxes, radial selectors,etc., where a user may enter or select privacy campaign data. Inexemplary embodiments, the Main Privacy Compliance Module 400 displayson the graphical user interface a prompt to create an electronic recordfor the privacy campaign. A user may choose to add a campaign, in whichcase the Main Privacy Compliance Module 400 receives a command to createthe electronic record for the privacy campaign, and in response to thecommand, creates a record for the campaign and digitally stores therecord for the campaign. The record for the campaign may be stored in,for example, storage 130, or a storage device associated with the MainPrivacy Compliance Module (e.g., a hard drive residing on Server 110, ora peripheral hard drive attached to Server 110).

The user may be a person who works in the Chief Privacy Officer'sorganization (e.g., a privacy office rep, or privacy officer). Theprivacy officer may be the user that creates the campaign record, andenters initial portions of campaign data (e.g., “high level” datarelated to the campaign), for example, a name for the privacy campaign,a description of the campaign, and a business group responsible foradministering the privacy operations related to that campaign (forexample, though the GUI shown in FIG. 6). The Main Privacy ComplianceModule 400 may also prompt the user to enter a person or entityresponsible for each campaign (e.g., the campaign's “owner”). The ownermay be tasked with the responsibility for ensuring or attempting toensure that the privacy policies or privacy laws associated withpersonal data related to a particular privacy campaign are beingcomplied with. In exemplary embodiments, the default owner of thecampaign may be the person who initiated the creation of the privacycampaign. That owner may be a person who works in the Chief PrivacyOfficer's organization (e.g., a privacy office rep, or privacy officer).The initial owner of the campaign may designate someone else to be theowner of the campaign. The designee may be, for example, arepresentative of some business unit within the organization (a businessrep). Additionally, more than one owner may be assigned. For example,the user may assign a primary business rep, and may also assign aprivacy office rep as owners of the campaign.

In many instances, some or most of the required information related tothe privacy campaign record might not be within the knowledge of thedefault owner (i.e., the privacy office rep). The Main Data ComplianceModule 400 can be operable to allow the creator of the campaign record(e.g., a privacy officer rep) to designate one or more othercollaborators to provide at least one of the data inputs for thecampaign data. Different collaborators, which may include the one ormore owners, may be assigned to different questions, or to specificquestions within the context of the privacy campaign. Additionally,different collaborators may be designated to respond to pats ofquestions. Thus, portions of campaign data may be assigned to differentindividuals.

Still referring to FIG. 4, if at step 415 the Main Privacy ComplianceModule 400 has received an input from a user to designate a new ownerfor the privacy campaign that was created, then at step 420, the MainPrivacy Compliance Module 400 may notify that individual via a suitablenotification that the privacy campaign has been assigned to him or her.Prior to notification, the Main Privacy Compliance Module 400 maydisplay a field that allows the creator of the campaign to add apersonalized message to the newly assigned owner of the campaign to beincluded with that notification. In exemplary embodiments, thenotification may be in the form of an email message. The email mayinclude the personalized message from the assignor, a standard messagethat the campaign has been assigned to him/her, the deadline forcompleting the campaign entry, and instructions to log in to the systemto complete the privacy campaign entry (along with a hyperlink thattakes the user to a GUI providing access to the Main Privacy ComplianceModule 400. Also included may be an option to reply to the email if anassigned owner has any questions, or a button that when clicked on,opens up a chat window (i.e., instant messenger window) to allow thenewly assigned owner and the assignor a GUI in which they are able tocommunicate in real-time. An example of such a notification appears inFIG. 16 below. In addition to owners, collaborators that are assigned toinput portions of campaign data may also be notified through similarprocesses. In exemplary embodiments, The Main Privacy Compliance Module400 may, for example through a Communications Module, be operable tosend collaborators emails regarding their assignment of one or moreportions of inputs to campaign data. Or through the CommunicationsModule, selecting the commentators button brings up one or morecollaborators that are on-line (with the off-line users still able tosee the messages when they are back on-line. Alerts indicate that one ormore emails or instant messages await a collaborator.

At step 425, regardless of whether the owner is the user (i.e., thecreator of the campaign), “someone else” assigned by the user, or othercollaborators that may be designated with the task of providing one ormore items of campaign data, the Main Privacy Campaign Module 400 may beoperable to electronically receive campaign data inputs from one or moreusers related to the personal data related to a privacy campaign througha series of displayed computer-generated graphical user interfacesdisplaying a plurality of prompts for the data inputs. In exemplaryembodiments, through a step-by-step process, the Main Privacy CampaignModule may receive from one or more users' data inputs that includecampaign data like: (1) a description of the campaign; (2) one or moretypes of personal data to be collected and stored as part of thecampaign; (3) individuals from which the personal data is to becollected; (4) the storage location of the personal data, and (5)information regarding who will have access to the personal data. Theseinputs may be obtained, for example, through the graphical userinterfaces shown in FIGS. 8 through 13, wherein the Main ComplianceModule 400 presents on sequentially appearing GUIs the prompts for theentry of each of the enumerated campaign data above. The Main ComplianceModule 400 may process the campaign data by electronically associatingthe campaign data with the record for the campaign and digitally storingthe campaign data with the record for the campaign. The campaign datamay be digitally stored as data elements in a database residing in amemory location in the server 120, a peripheral storage device attachedto the server, or one or more storage devices connected to the network(e.g., storage 130). If campaign data inputs have been assigned to oneor more collaborators, but those collaborators have not input the datayet, the Main Compliance Module 400 may, for example through theCommunications Module, sent an electronic message (such as an email)alerting the collaborators and owners that they have not yet suppliedtheir designated portion of campaign data.

III. Privacy Campaign Information Display

At step 430, Main Privacy Compliance Module 400 may, in exemplaryembodiments, call upon a Risk Assessment Module 430 that may determineand assign a Risk Level for the privacy campaign, based wholly or inpart on the information that the owner(s) have input. The RiskAssessment Module 430 will be discussed in more detail below.

At step 432, Main Privacy Compliance Module 400 may in exemplaryembodiments, call upon a Privacy Audit Module 432 that may determine anaudit schedule for each privacy campaign, based, for example, wholly orin part on the campaign data that the owner(s) have input, the RiskLevel assigned to a campaign, and/or any other suitable factors. ThePrivacy Audit Module 432 may also be operable to display the status ofan audit for each privacy campaign. The Privacy Audit Module 432 will bediscussed in more detail below.

At step 435, the Main Privacy Compliance Module 400 may generate anddisplay a GUI showing an inventory page (e.g., inventory page 1500) thatincludes information associated with each campaign. That information mayinclude information input by a user (e.g., one or more owners), orinformation calculated by the Main Privacy Compliance Module 400 orother modules. Such information may include for example, the name of thecampaign, the status of the campaign, the source of the campaign, thestorage location of the personal data related to the campaign, etc. Theinventory page 1500 may also display an indicator representing the RiskLevel (as mentioned, determined for each campaign by the Risk AssessmentModule 430), and audit information related to the campaign that wasdetermined by the Privacy Audit Module (see below). The inventory page1500 may be the landing page displayed to users that access the system.Based on the login information received from the user, the Main PrivacyCompliance Module may determine which campaigns and campaign data theuser is authorized to view, and display only the information that theuser is authorized to view. Also from the inventory page 1500, a usermay add a campaign (discussed above in step 405), view more informationfor a campaign, or edit information related to a campaign (see, e.g.,FIGS. 15, 16, 17).

If other commands from the inventory page are received (e.g., add acampaign, view more information, edit information related to thecampaign), then step 440, 445, and/or 450 may be executed.

At step 440, if a command to view more information has been received ordetected, then at step 445, the Main Privacy Compliance Module 400 maypresent more information about the campaign, for example, on a suitablecampaign information page 1500. At this step, the Main PrivacyCompliance Module 400 may invoke a Data Flow Diagram Module (describedin more detail below). The Data Flow Diagram Module may generate a flowdiagram that shows, for example, visual indicators indicating whetherdata is confidential and/or encrypted (see, e.g., FIG. 1600 below).

At step 450, if the system has received a request to edit a campaign,then, at step 455, the system may display a dialog page that allows auser to edit information regarding the campaign (e.g., edit campaigndialog 1700).

At step 460, if the system has received a request to add a campaign, theprocess may proceed back to step 405.

C. Risk Assessment Module

FIG. 5 illustrates an exemplary process for determining a Risk Level andOverall Risk Assessment for a particular privacy campaign performed byRisk Assessment Module 430.

I. Determining Risk Level

In exemplary embodiments, the Risk Assessment Module 430 may be operableto calculate a Risk Level for a campaign based on the campaign datarelated to the personal data associated with the campaign. The RiskAssessment Module may associate the Risk Level with the record for thecampaign and digitally store the Risk Level with the record for thecampaign.

The Risk Assessment Module 430 may calculate this Risk Level based onany of various factors associated with the campaign. The Risk AssessmentModule 430 may determine a plurality of weighting factors based upon,for example: (1) the nature of the sensitive information collected aspart of the campaign (e.g., campaigns in which medical information,financial information or non-public personal identifying information iscollected may be indicated to be of higher risk than those in which onlypublic information is collected, and thus may be assigned a highernumerical weighting factor); (2) the location in which the informationis stored (e.g., campaigns in which data is stored in the cloud may bedeemed higher risk than campaigns in which the information is storedlocally); (3) the number of individuals who have access to theinformation (e.g., campaigns that permit relatively large numbers ofindividuals to access the personal data may be deemed more risky thanthose that allow only small numbers of individuals to access the data);(4) the length of time that the data will be stored within the system(e.g., campaigns that plan to store and use the personal data over along period of time may be deemed more risky than those that may onlyhold and use the personal data for a short period of time); (5) theindividuals whose sensitive information will be stored (e.g., campaignsthat involve storing and using information of minors may be deemed ofgreater risk than campaigns that involve storing and using theinformation of adults); (6) the country of residence of the individualswhose sensitive information will be stored (e.g., campaigns that involvecollecting data from individuals that live in countries that haverelatively strict privacy laws may be deemed more risky than those thatinvolve collecting data from individuals that live in countries thathave relative lax privacy laws). It should be understood that any othersuitable factors may be used to assess the Risk Level of a particularcampaign, including any new inputs that may need to be added to the riskcalculation.

In particular embodiments, one or more of the individual factors may beweighted (e.g., numerically weighted) according to the deemed relativeimportance of the factor relative to other factors (i.e., Relative RiskRating).

These weightings may be customized from organization to organization,and/or according to different applicable laws. In particularembodiments, the nature of the sensitive information will be weightedhigher than the storage location of the data, or the length of time thatthe data will be stored.

In various embodiments, the system uses a numerical formula to calculatethe Risk Level of a particular campaign. This formula may be, forexample: Risk Level for campaign=(Weighting Factor of Factor1)*(Relative Risk Rating of Factor 1)+(Weighting Factor of Factor2)*(Relative Risk Rating of Factor 2)+ . . . (Weighting Factor of FactorN)*(Relative Risk Rating of Factor N). As a simple example, the RiskLevel for a campaign that only collects publicly available informationfor adults and that stores the information locally for a short period ofseveral weeks might be determined as Risk Level=(Weighting Factor ofNature of Sensitive Information)*(Relative Risk Rating of ParticularSensitive Information to be Collected)+(Weighting Factor of Individualsfrom which Information is to be Collected)*(Relative Risk Rating ofIndividuals from which Information is to be Collected)+(Weighting Factorof Duration of Data Retention)*(Relative Risk Rating of Duration of DataRetention)+(Weighting Factor of Individuals from which Data is to beCollected)*(Relative Risk Rating of Individuals from which Data is to beCollected). In this example, the Weighting Factors may range, forexample from 1-5, and the various Relative Risk Ratings of a factor mayrange from 1-10. However, the system may use any other suitable ranges.

In particular embodiments, the Risk Assessment Module 430 may havedefault settings for assigning Overall Risk Assessments to respectivecampaigns based on the numerical Risk Level value determined for thecampaign, for example, as described above. The organization may alsomodify these settings in the Risk Assessment Module 430 by assigning itsown Overall Risk Assessments based on the numerical Risk Level. Forexample, the Risk Assessment Module 430 may, based on default or userassigned settings, designate: (1) campaigns with a Risk Level of 1-7 as“low risk” campaigns, (2) campaigns with a Risk Level of 8-15 as “mediumrisk” campaigns; (3) campaigns with a Risk Level of over 16 as “highrisk” campaigns. As show below, in an example inventory page 1500, theOverall Risk Assessment for each campaign can be indicated by up/downarrow indicators, and further, the arrows may have different shading (orcolor, or portions shaded) based upon this Overall Risk Assessment. Theselected colors may be conducive for viewing by those who suffer fromcolor blindness.

Thus, the Risk Assessment Module 430 may be configured to automaticallycalculate the numerical Risk Level for each campaign within the system,and then use the numerical Risk Level to assign an appropriate OverallRisk Assessment to the respective campaign. For example, a campaign witha Risk Level of 5 may be labeled with an Overall Risk Assessment as “LowRisk”. The system may associate both the Risk Level and the Overall RiskAssessment with the campaign and digitally store them as part of thecampaign record.

II. Exemplary Process for Assessing Risk

Accordingly, as shown in FIG. 5, in exemplary embodiments, the RiskAssessment Module 430 electronically retrieves from a database (e.g.,storage device 130) the campaign data associated with the record for theprivacy campaign. It may retrieve this information serially, or inparallel. At step 505, the Risk Assessment Module 430 retrievesinformation regarding (1) the nature of the sensitive informationcollected as part of the campaign. At step 510, the Risk AssessmentModule 430 retrieves information regarding the (2) the location in whichthe information related to the privacy campaign is stored. At step 515,the Risk Assessment Module 430 retrieves information regarding (3) thenumber of individuals who have access to the information. At step 520,the Risk Assessment Module retrieves information regarding (4) thelength of time that the data associated with a campaign will be storedwithin the System 100. At step 525, the Risk Assessment Module retrievesinformation regarding (5) the individuals whose sensitive informationwill be stored. At step 530, the Risk Assessment Module retrievesinformation regarding (6) the country of residence of the individualswhose sensitive information will be stored.

At step 535, the Risk Assessment Module takes into account any usercustomizations to the weighting factors related to each of the retrievedfactors from steps 505, 510, 515, 520, 525, and 530. At steps 540 and545, the Risk Assessment Module applies either default settings to theweighting factors (which may be based on privacy laws), orcustomizations to the weighting factors. At step 550, the RiskAssessment Module determines a plurality of weighting factors for thecampaign. For example, for the factor related to the nature of thesensitive information collected as part of the campaign, a weightingfactor of 1-5 may be assigned based on whether non-public personalidentifying information is collected.

At step 555, the Risk Assessment Module takes into account any usercustomizations to the Relative Risk assigned to each factor, and at step560 and 565, will either apply default values (which can be based onprivacy laws) or the customized values for the Relative Risk. At step570, the Risk Assessment Module assigns a relative risk rating for eachof the plurality of weighting factors. For example, the relative riskrating for the location of the information of the campaign may beassigned a numerical number (e.g., from 1-10) that is lower than thenumerical number assigned to the Relative Risk Rating for the length oftime that the sensitive information for that campaign is retained.

At step 575, the Risk Assessment Module 430 calculates the relative riskassigned to the campaign based upon the plurality of Weighting Factorsand the Relative Risk Rating for each of the plurality of factors. As anexample, the Risk Assessment Module 430 may make this calculation usingthe formula of Risk Level=(Weighting Factor of Factor 1)*(Relative RiskRating of Factor 1)+(Weighting Factor of Factor 2)*(Relative Risk Ratingof Factor 2)+ . . . (Weighting Factor of Factor N)*(Relative Risk Ratingof Factor N).

At step 580, based upon the numerical value derived from step 575, theRisk Assessment Module 430 may determine an Overall Risk Assessment forthe campaign. The Overall Risk Assessment determination may be made forthe privacy campaign may be assigned based on the following criteria,which may be either a default or customized setting: (1) campaigns witha Risk Level of 1-7 as “low risk” campaigns, (2) campaigns with a RiskLevel of 8-15 as “medium risk” campaigns; (3) campaigns with a RiskLevel of over 16 as “high risk” campaigns. The Overall Risk Assessmentis then associated and stored with the campaign record.

D. Privacy Audit Module

The System 100 may determine an audit schedule for each campaign, andindicate, in a particular graphical user interface (e.g., inventory page1500), whether a privacy audit is coming due (or is past due) for eachparticular campaign and, if so, when the audit is/was due. The System100 may also be operable to provide an audit status for each campaign,and alert personnel of upcoming or past due privacy audits. To furtherthe retention of evidence of compliance, the System 100 may also receiveand store evidence of compliance. A Privacy Audit Module 432, mayfacilitate these functions.

I. Determining a Privacy Audit Schedule and Monitoring Compliance

In exemplary embodiments, the Privacy Audit Module 432 is adapted toautomatically schedule audits and manage compliance with the auditschedule. In particular embodiments, the system may allow a user tomanually specify an audit schedule for each respective campaign. ThePrivacy Audit Module 432 may also automatically determine, and save tomemory, an appropriate audit schedule for each respective campaign,which in some circumstances, may be editable by the user.

The Privacy Audit Module 432 may automatically determine the auditschedule based on the determined Risk Level of the campaign. Forexample, all campaigns with a Risk Level less than 10 may have a firstaudit schedule and all campaigns with a Risk Level of 10 or more mayhave a second audit schedule. The Privacy Audit Module may also beoperable determine the audit schedule based on the Overall RiskAssessment for the campaign (e.g., “low risk” campaigns may have a firstpredetermined audit schedule, “medium risk” campaigns may have a secondpredetermined audit schedule, “high risk” campaigns may have a thirdpredetermined audit schedule, etc.).

In particular embodiments, the Privacy Audit Module 432 mayautomatically facilitate and monitor compliance with the determinedaudit schedules for each respective campaign. For example, the systemmay automatically generate one or more reminder emails to the respectiveowners of campaigns as the due date approaches. The system may also beadapted to allow owners of campaigns, or other users, to submit evidenceof completion of an audit (e.g., by for example, submitting screen shotsthat demonstrate that the specified parameters of each campaign arebeing followed). In particular embodiments, the system is configuredfor, in response to receiving sufficient electronic informationdocumenting completion of an audit, resetting the audit schedule (e.g.,scheduling the next audit for the campaign according to a determinedaudit schedule, as determined above).

II. Exemplary Privacy Audit Process

FIG. 6 illustrates an exemplary process performed by a Privacy AuditModule 432 for assigning a privacy audit schedule and facilitating andmanaging compliance for a particular privacy campaign. At step 605, thePrivacy Audit Module 432 retrieves the Risk Level associated with theprivacy campaign. In exemplary embodiments, the Risk Level may be anumerical number, as determined above by the Risk Assessment Module 430.If the organization chooses, the Privacy Audit Module 432 may use theOverall Risk Assessment to determine which audit schedule for thecampaign to assign.

At step 610, based on the Risk Level of the campaign (or the OverallRisk Assessment), or based on any other suitable factor, the PrivacyAudit Module 432 can assign an audit schedule for the campaign. Theaudit schedule may be, for example, a timeframe (i.e., a certain amountof time, such as number of days) until the next privacy audit on thecampaign to be performed by the one or more owners of the campaign. Theaudit schedule may be a default schedule. For example, the Privacy AuditModule can automatically apply an audit schedule of 120 days for anycampaign having Risk Level of 10 and above. These default schedules maybe modifiable. For example, the default audit schedule for campaignshaving a Risk Level of 10 and above can be changed from 120 days to 150days, such that any campaign having a Risk Level of 10 and above isassigned the customized default audit schedule (i.e., 150 days).Depending on privacy laws, default policies, authority overrides, or thepermission level of the user attempting to modify this default, thedefault might not be modifiable.

At step 615, after the audit schedule for a particular campaign hasalready been assigned, the Privacy Audit Module 432 determines if a userinput to modify the audit schedule has been received. If a user input tomodify the audit schedule has been received, then at step 620, thePrivacy Audit Module 432 determines whether the audit schedule for thecampaign is editable (i.e., can be modified). Depending on privacy laws,default policies, authority overrides, or the permission level of theuser attempting to modify the audit schedule, the campaign's auditschedule might not be modifiable.

At step 625, if the audit schedule is modifiable, then the Privacy AuditModule will allow the edit and modify the audit schedule for thecampaign. If at step 620 the Privacy Audit Module determines that theaudit schedule is not modifiable, in some exemplary embodiments, theuser may still request permission to modify the audit schedule. Forexample, the Privacy Audit Module 432 can at step 630 provide anindication that the audit schedule is not editable, but also provide anindication to the user that the user may contact through the system oneor more persons having the authority to grant or deny permission tomodify the audit schedule for the campaign (i.e., administrators) togain permission to edit the field. The Privacy Audit Module 432 maydisplay an on-screen button that, when selected by the user, sends anotification (e.g., an email) to an administrator. The user can thusmake a request to the modify the audit schedule for the campaign in thismanner.

At step 635, the Privacy Audit Module may determine whether permissionhas been granted by an administrator to allow a modification to theaudit schedule. It may make this determination based on whether it hasreceived input from an administrator to allow modification of the auditschedule for the campaign. If the administrator has granted permission,the Privacy Audit Module 432 at step 635 may allow the edit of the auditschedule. If at step 640, a denial of permission is received from theadministrator, or if a certain amount of time has passed (which may becustomized or based on a default setting), the Privacy Audit Module 432retains the audit schedule for the campaign by not allowing anymodifications to the schedule, and the process may proceed to step 645.The Privacy Audit Module may also send a reminder to the administratorthat a request to modify the audit schedule for a campaign is pending.

At step 645, the Privacy Audit Module 432 determines whether a thresholdamount of time (e.g., number of days) until the audit has been reached.This threshold may be a default value, or a customized value. If thethreshold amount of time until an audit has been reached, the PrivacyAudit Module 432 may at step 650 generate an electronic alert. The alertcan be a message displayed to the collaborator the next time thecollaborator logs into the system, or the alert can be an electronicmessage sent to one or more collaborators, including the campaignowners. The alert can be, for example, an email, an instant message, atext message, or one or more of these communication modalities. Forexample, the message may state, “This is a notification that a privacyaudit for Campaign Internet Browsing History is scheduled to occur in 90days.” More than one threshold may be assigned, so that the owner of thecampaign receives more than one alert as the scheduled privacy auditdeadline approaches. If the threshold number of days has not beenreached, the Privacy Audit Module 432 will continue to evaluate whetherthe threshold has been reached (i.e., back to step 645).

In exemplary embodiments, after notifying the owner of the campaign ofan impending privacy audit, the Privacy Audit Module may determine atstep 655 whether it has received any indication or confirmation that theprivacy audit has been completed. In example embodiments, the PrivacyAudit Module allows for evidence of completion to be submitted, and ifsufficient, the Privacy Audit Module 432 at step 660 resets the counterfor the audit schedule for the campaign. For example, a privacy auditmay be confirmed upon completion of required electronic forms in whichone or more collaborators verify that their respective portions of theaudit process have been completed. Additionally, users can submitphotos, screen shots, or other documentation that show that theorganization is complying with that user's assigned portion of theprivacy campaign. For example, a database administrator may take ascreen shot showing that all personal data from the privacy campaign isbeing stored in the proper database and submit that to the system todocument compliance with the terms of the campaign.

If at step 655, no indication of completion of the audit has beenreceived, the Privacy Audit Module 432 can determine at step 665 whetheran audit for a campaign is overdue (i.e., expired). If it is notoverdue, the Privacy Audit Module 432 will continue to wait for evidenceof completion (e.g., step 655). If the audit is overdue, the PrivacyAudit Module 432 at step 670 generates an electronic alert (e.g., anemail, instant message, or text message) to the campaign owner(s) orother administrators indicating that the privacy audit is overdue, sothat the organization can take responsive or remedial measures.

In exemplary embodiments, the Privacy Audit Module 432 may also receivean indication that a privacy audit has begun (not shown), so that thestatus of the audit when displayed on inventory page 1500 shows thestatus of the audit as pending. While the audit process is pending, thePrivacy Audit Module 432 may be operable to generate reminders to besent to the campaign owner(s), for example, to remind the owner of thedeadline for completing the audit.

E. Data Flow Diagram Module

The system 110 may be operable to generate a data flow diagram based onthe campaign data entered and stored, for example in the mannerdescribed above.

I. Display of Security Indicators and Other Information

In various embodiments, a Data Flow Diagram Module is operable togenerate a flow diagram for display containing visual representations(e.g., shapes) representative of one or more parts of campaign dataassociated with a privacy campaign, and the flow of that informationfrom a source (e.g., customer), to a destination (e.g., an internetusage database), to which entities and computer systems have access(e.g., customer support, billing systems). Data Flow Diagram Module mayalso generate one or more security indicators for display. Theindicators may include, for example, an “eye” icon to indicate that thedata is confidential, a “lock” icon to indicate that the data, and/or aparticular flow of data, is encrypted, or an “unlocked lock” icon toindicate that the data, and/or a particular flow of data, is notencrypted. In the example shown in FIG. 16, the dotted arrow linesgenerally depict respective flows of data and the locked or unlockedlock symbols indicate whether those data flows are encrypted orunencrypted. The color of dotted lines representing data flows may alsobe colored differently based on whether the data flow is encrypted ornon-encrypted, with colors conducive for viewing by those who sufferfrom color blindness.

II. Exemplary Process Performed by Data Flow Diagram Module

FIG. 7 shows an example process performed by the Data Flow DiagramModule 700. At step 705, the Data Flow Diagram retrieves campaign datarelated to a privacy campaign record. The campaign data may indicate,for example, that the sensitive information related to the privacycampaign contains confidential information, such as the social securitynumbers of a customer.

At step 710, the Data Flow Diagram Module 700 is operable to displayon-screen objects (e.g., shapes) representative of the Source,Destination, and Access, which indicate that information below theheading relates to the source of the personal data, the storagedestination of the personal data, and access related to the personaldata. In addition to campaign data regarding Source, Destination, andAccess, the Data Flow Diagram Module 700 may also account for userdefined attributes related to personal data, which may also be displayedas on-screen objects. The shape may be, for example, a rectangular box(see, e.g., FIG. 16). At step 715, the Data Flow Diagram Module 700 maydisplay a hyperlink label within the on-screen object (e.g., as shown inFIG. 16, the word “Customer” may be a hyperlink displayed within therectangular box) indicative of the source of the personal data, thestorage destination of the personal data, and access related to thepersonal data, under each of the respective headings. When a user hoversover the hyperlinked word, the Data Flow Diagram is operable to displayadditional campaign data relating to the campaign data associated withthe hyperlinked word. The additional information may also be displayedin a pop up, or a new page. For example, FIG. 16 shows that if a userhovers over the words “Customer,” the Data Flow Diagram Module 700displays what customer information is associated with the campaign(e.g., the Subscriber ID, the IP and Mac Addresses associated with theCustomer, and the customer's browsing and usage history). The Data FlowDiagram Module 700 may also generate for display information relating towhether the source of the data includes minors, and whether consent wasgiven by the source to use the sensitive information, as well as themanner of the consent (for example, through an End User LicenseAgreement (EULA)).

At step 720, the Data Flow Diagram Module 700 may display one or moreparameters related to backup and retention of personal data related tothe campaign, including in association with the storage destination ofthe personal data. As an example, Data Flow Diagram 1615 of FIG. 16displays that the information in the Internet Usage database is backedup, and the retention related to that data is Unknown.

At 725, the Data Flow Diagram Module 700 determines, based on thecampaign data associated with the campaign, whether the personal datarelated to each of the hyperlink labels is confidential. At Step 730, ifthe personal data related to each hyperlink label is confidential, theData Flow Diagram Module 700 generates visual indicator indicatingconfidentiality of that data (e.g., an “eye” icon, as show in Data FlowDiagram 1615). If there is no confidential information for that box,then at step 735, no indicators are displayed. While this is an exampleof the generation of indicators for this particular hyperlink, inexemplary embodiments, any user defined campaign data may visualindicators that may be generated for it.

At step 740, the Data Flow Diagram Module 700 determined whether any ofthe data associated with the source, stored in a storage destination,being used by an entity or application, or flowing to one or moreentities or systems (i.e., data flow) associated with the campaign isdesignated as encrypted. If the data is encrypted, then at step 745 theData Flow Diagram Module 700 may generate an indicator that the personaldata is encrypted (e.g., a “lock” icon). If the data is non-encrypted,then at step 750, the Data Flow Diagram Module 700 displays an indicatorto indicate that the data or particular flow of data is not encrypted.(e.g., an “unlocked lock” icon). An example of a data flow diagram isdepicted in FIG. 9. Additionally, the data flow diagram lines may becolored differently to indicate whether the data flow is encrypted orunencrypted, wherein the colors can still be distinguished by acolor-blind person.

F. Communications Module

In exemplary embodiments, a Communications Module of the System 100 mayfacilitate the communications between various owners and personnelrelated to a privacy campaign. The Communications Module may retaincontact information (e.g., emails or instant messaging contactinformation) input by campaign owners and other collaborators. TheCommunications Module can be operable to take a generated notificationor alert (e.g., alert in step 670 generated by Privacy Audit Module 432)and instantiate an email containing the relevant information. Asmentioned above, the Main Privacy Compliance Module 400 may, for examplethrough a communications module, be operable to send collaboratorsemails regarding their assignment of one or more portions of inputs tocampaign data. Or through the communications module, selecting thecommentators button brings up one or more collaborators that are on-line

In exemplary embodiments, the Communications Module can also, inresponse to a user request (e.g., depressing the “comment” button showin FIG. 9, FIG. 10, FIG. 11, FIG. 12, FIG. 13, FIG. 16), instantiate aninstant messaging session and overlay the instant messaging session overone or more portions of a GUI, including a GUI in which a user ispresented with prompts to enter or select information. An example ofthis instant messaging overlay feature orchestrated by theCommunications Module is shown in FIG. 17. While a real-time messagesession may be generated, off-line users may still able to see themessages when they are back on-line.

The Communications Module may facilitate the generation of alerts thatindicate that one or more emails or instant messages await acollaborator.

If campaign data inputs have been assigned to one or more collaborators,but those collaborators have not input the data yet, the CommunicationsModule, may facilitate the sending of an electronic message (such as anemail) alerting the collaborators and owners that they have not yetsupplied their designated portion of campaign data.

Exemplary User Experience

In the exemplary embodiments of the system for operationalizing privacycompliance, adding a campaign (i.e., data flow) comprises gatheringinformation that includes several phases: (1) a description of thecampaign; (2) the personal data to be collected as part of the campaign;(3) who the personal data relates to; (4) where the personal data bestored; and (5) who will have access to the indicated personal data.

A. FIG. 8: Campaign Record Creation and Collaborator Assignment

FIG. 8 illustrates an example of the first phase of informationgathering to add a campaign. In FIG. 8, a description entry dialog 800may have several fillable/editable fields and drop-down selectors. Inthis example, the user may fill out the name of the campaign in theShort Summary (name) field 805, and a description of the campaign in theDescription field 810. The user may enter or select the name of thebusiness group (or groups) that will be accessing personal data for thecampaign in the Business Group field 815. The user may select theprimary business representative responsible for the campaign (i.e., thecampaign's owner), and designate him/herself, or designate someone elseto be that owner by entering that selection through the Someone Elsefield 820. Similarly, the user may designate him/herself as the privacyoffice representative owner for the campaign, or select someone elsefrom the second Someone Else field 825. At any point, a user assigned asthe owner may also assign others the task of selecting or answering anyquestion related to the campaign. The user may also enter one or moretag words associated with the campaign in the Tags field 830. Afterentry, the tag words may be used to search for campaigns, or used tofilter for campaigns (for example, under Filters 845). The user mayassign a due date for completing the campaign entry, and turn remindersfor the campaign on or off. The user may save and continue, or assignand close.

In example embodiments, some of the fields may be filled in by a user,with suggest-as-you-type display of possible field entries (e.g.,Business Group field 815), and/or may include the ability for the userto select items from a drop-down selector (e.g., drop-down selectors 840a, 840 b, 840 c). The system may also allow some fields to stay hiddenor unmodifiable to certain designated viewers or categories of users.For example, the purpose behind a campaign may be hidden from anyone whois not the chief privacy officer of the company, or the retentionschedule may be configured so that it cannot be modified by anyoneoutside of the organization's′ legal department.

B. FIG. 9: Collaborator Assignment Notification and Description Entry

Moving to FIG. 9, in example embodiments, if another businessrepresentative (owner), or another privacy office representative hasbeen assigned to the campaign (e.g., John Doe in FIG. 8), the system maysend a notification (e.g., an electronic notification) to the assignedindividual, letting them know that the campaign has been assigned tohim/her. FIG. 9 shows an example notification 900 sent to John Doe thatis in the form of an email message. The email informs him that thecampaign “Internet Usage Tracking” has been assigned to him, andprovides other relevant information, including the deadline forcompleting the campaign entry and instructions to log in to the systemto complete the campaign (data flow) entry (which may be done, forexample, using a suitable “wizard” program). The user that assigned Johnownership of the campaign may also include additional comments 905 to beincluded with the notification 900. Also included may be an option toreply to the email if an assigned owner has any questions.

In this example, if John selects the hyperlink Privacy Portal 910, he isable to access the system, which displays a landing page 915. Thelanding page 915 displays a Getting Started section 920 to familiarizenew owners with the system, and also displays an “About This Data Flow”section 930 showing overview information for the campaign.

C. FIG. 10: What Personal Data is Collected

Moving to FIG. 10, after the first phase of campaign addition (i.e.,description entry phase), the system may present the user (who may be asubsequently assigned business representative or privacy officer) with adialog 1000 from which the user may enter in the type of personal databeing collected.

In addition, questions are described generally as transitionalquestions, but the questions may also include one or more smartquestions in which the system is configured to: (1) pose an initialquestion to a user and, (2) in response to the user's answer satisfyingcertain criteria, presenting the user with one or more follow-upquestions. For example, in FIG. 10, if the user responds with a choiceto add personal data, the user may be additionally presented follow-upprompts, for example, the select personal data window overlaying screen800 that includes commonly used selections may include, for example,particular elements of an individual's contact information (e.g., name,address, email address), Financial/Billing Information (e.g., creditcard number, billing address, bank account number), Online Identifiers(e.g., IP Address, device type, MAC Address), Personal Details(Birthdate, Credit Score, Location), or Telecommunication Data (e.g.,Call History, SMS History, Roaming Status). The System 100 is alsooperable to pre-select or automatically populate choices—for example,with commonly-used selections 1005, some of the boxes may already bechecked. The user may also use a search/add tool 1010 to search forother selections that are not commonly used and add another selection.Based on the selections made, the user may be presented with moreoptions and fields. For example, if the user selected “Subscriber ID” aspersonal data associated with the campaign, the user may be prompted toadd a collection purpose under the heading Collection Purpose 1015, andthe user may be prompted to provide the business reason why a SubscriberID is being collected under the “Describe Business Need” heading 1020.

D. FIG. 11: Who Personal Data is Collected From

As displayed in the example of FIG. 11, the third phase of adding acampaign may relate to entering and selecting information regarding whothe personal data is gathered from. As noted above, the personal datamay be gathered from, for example, one or more Subjects 100. In theexemplary “Collected From” dialog 1100, a user may be presented withseveral selections in the “Who Is It Collected From” section 1105. Theseselections may include whether the personal data was to be collectedfrom an employee, customer, or other entity. Any entities that are notstored in the system may be added. The selections may also include, forexample, whether the data was collected from a current or prospectivesubject (e.g., a prospective employee may have filled out an employmentapplication with his/her social security number on it). Additionally,the selections may include how consent was given, for example through anend user license agreement (EULA), on-line Opt-in prompt, Impliedconsent, or an indication that the user is not sure. Additionalselections may include whether the personal data was collected from aminor, and where the subject is located.

E. FIG. 12: Where is the Personal Data Stored

FIG. 12 shows an example “Storage Entry” dialog screen 1200, which is agraphical user interface that a user may use to indicate whereparticular sensitive information is to be stored within the system. Fromthis section, a user may specify, in this case for the Internet UsageHistory campaign, the primary destination of the personal data 1220 andhow long the personal data is to be kept 1230. The personal data may behoused by the organization (in this example, an entity called “Acme”) ora third party. The user may specify an application associated with thepersonal data's storage (in this example, ISP Analytics), and may alsospecify the location of computing systems (e.g., servers) that will bestoring the personal data (e.g., a Toronto data center). Otherselections indicate whether the data will be encrypted and/or backed up.

The system also allows the user to select whether the destinationsettings are applicable to all the personal data of the campaign, orjust select data (and if so, which data). In FIG. 12, the user may alsoselect and input options related to the retention of the personal datacollected for the campaign (e.g., How Long Is It Kept 1230). Theretention options may indicate, for example, that the campaign'spersonal data should be deleted after a per-determined period of timehas passed (e.g., on a particular date), or that the campaign's personaldata should be deleted in accordance with the occurrence of one or morespecified events (e.g., in response to the occurrence of a particularevent, or after a specified period of time passes after the occurrenceof a particular event), and the user may also select whether backupsshould be accounted for in any retention schedule. For example, the usermay specify that any backups of the personal data should be deleted (or,alternatively, retained) when the primary copy of the personal data isdeleted.

F. FIG. 13: Who and What Systems have Access to Personal Data

FIG. 13 describes an example Access entry dialog screen 1300. As part ofthe process of adding a campaign or data flow, the user may specify inthe “Who Has Access” section 1305 of the dialog screen 1300. In theexample shown, the Customer Support, Billing, and Government groupswithin the organization are able to access the Internet Usage Historypersonal data collected by the organization. Within each of these accessgroups, the user may select the type of each group, the format in whichthe personal data was provided, and whether the personal data isencrypted. The access level of each group may also be entered. The usermay add additional access groups via the Add Group button 1310.

G. Facilitating Entry of Campaign Data, Including Chat Shown in FIG. 14

As mentioned above, to facilitate the entry of data collected throughthe example GUIs shown in FIGS. 8 through 12, in exemplary embodiments,the system is adapted to allow the owner of a particular campaign (orother user) to assign certain sections of questions, or individualquestions, related to the campaign to contributors other than the owner.This may eliminate the need for the owner to contact other users todetermine information that they don't know and then enter theinformation into the system themselves. Rather, in various embodiments,the system facilitates the entry of the requested information directlyinto the system by the assigned users.

In exemplary embodiments, after the owner assigns a respectiveresponsible party to each question or section of questions that need tobe answered in order to fully populate the data flow, the system mayautomatically contact each user (e.g., via an appropriate electronicmessage) to inform the user that they have been assigned to complete thespecified questions and/or sections of questions, and provide thoseusers with instructions as to how to log into the system to enter thedata. The system may also be adapted to periodically follow up with eachuser with reminders until the user completes the designated tasks. Asdiscussed elsewhere herein, the system may also be adapted to facilitatereal-time text or voice communications between multiple collaborators asthey work together to complete the questions necessary to define thedata flow. Together, these features may reduce the amount of time andeffort needed to complete each data flow.

To further facilitate collaboration, as shown FIG. 14, in exemplaryembodiments, the System 100 is operable to overlay an instant messagingsession over a GUI in which a user is presented with prompts to enter orselect information. In FIG. 14, a communications module is operable tocreate an instant messaging session window 1405 that overlays the Accessentry dialog screen 1400. In exemplary embodiments, the CommunicationsModule, in response to a user request (e.g., depressing the “comment”button show in FIG. 9, FIG. 10, FIG. 11, FIG. 12, FIG. 13, FIG. 16),instantiates an instant messaging session and overlays the instantmessaging session over one or more portions of the GUI.

H: FIG. 15: Campaign Inventory Page

After new campaigns have been added, for example using the exemplaryprocesses explained in regard to FIGS. 8-13, the users of the system mayview their respective campaign or campaigns, depending on whether theyhave access to the campaign. The chief privacy officer, or anotherprivacy office representative, for example, may be the only user thatmay view all campaigns. A listing of all of the campaigns within thesystem may be viewed on, for example, inventory page 1500 (see below).Further details regarding each campaign may be viewed via, for example,campaign information page 1600, which may be accessed by selecting aparticular campaign on the inventory page 1500. And any informationrelated to the campaign may be edited or added through, for example, theedit campaign dialog 1700 screen. Certain fields or information may notbe editable, depending on the particular user's level of access. A usermay also add a new campaign using a suitable user interface, such as thegraphical user interface shown in FIG. 15 or FIG. 16.

In example embodiments, the System 100 (and more particularly, the MainPrivacy Compliance Module 400) may use the history of past entries tosuggest selections for users during campaign creation and entry ofassociated data. As an example, in FIG. 10, if most entries that containthe term “Internet” and have John Doe as the business rep assigned tothe campaign have the items Subscriber ID, IP Address, and MAC Addressselected, then the items that are commonly used may display aspre-selected items the Subscriber ID, IP address, and MAC Address eachtime a campaign is created having Internet in its description and JohnDoe as its business rep.

FIG. 15 describes an example embodiment of an inventory page 1500 thatmay be generated by the Main Privacy Compliance Module 400. Theinventory page 1500 may be represented in a graphical user interface.Each of the graphical user interfaces (e.g., webpages, dialog boxes,etc.) presented in this application may be, in various embodiments, anHTML-based page capable of being displayed on a web browser (e.g.,Firefox, Internet Explorer, Google Chrome, Opera, etc.), or any othercomputer-generated graphical user interface operable to displayinformation, including information having interactive elements (e.g., aniOS, Mac OS, Android, Linux, or Microsoft Windows application). Thewebpage displaying the inventory page 1500 may include typical featuressuch as a scroll-bar, menu items, as well as buttons for minimizing,maximizing, and closing the webpage. The inventory page 1500 may beaccessible to the organization's chief privacy officer, or any other ofthe organization's personnel having the need, and/or permission, to viewpersonal data.

Still referring to FIG. 15, inventory page 1500 may display one or morecampaigns listed in the column heading Data Flow Summary 1505, as wellas other information associated with each campaign, as described herein.Some of the exemplary listed campaigns include Internet Usage History1510, Customer Payment Information, Call History Log, Cellular RoamingRecords, etc. A campaign may represent, for example, a businessoperation that the organization is engaged in may require the use ofpersonal data, which may include the personal data of a customer. In thecampaign Internet Usage History 1510, for example, a marketingdepartment may need customers' on-line browsing patterns to runanalytics. Examples of more information that may be associated with theInternet Usage History 1510 campaign will be presented in FIG. 4 andFIG. 5. In example embodiments, clicking on (i.e., selecting) the columnheading Data Flow Summary 1505 may result in the campaigns being sortedeither alphabetically, or reverse alphabetically.

The inventory page 1500 may also display the status of each campaign, asindicated in column heading Status 1515. Exemplary statuses may include“Pending Review”, which means the campaign has not been approved yet,“Approved,” meaning the data flow associated with that campaign has beenapproved, “Audit Needed,” which may indicate that a privacy audit of thepersonal data associated with the campaign is needed, and “ActionRequired,” meaning that one or more individuals associated with thecampaign must take some kind of action related to the campaign (e.g.,completing missing information, responding to an outstanding message,etc.). In certain embodiments, clicking on (i.e., selecting) the columnheading Status 1515 may result in the campaigns being sorted by status.

The inventory page 1500 of FIG. 15 may list the “source” from which thepersonal data associated with a campaign originated, under the columnheading “Source” 1520. The sources may include one or more of thesubjects 100 in example FIG. 1. As an example, the campaign “InternetUsage History” 1510 may include a customer's IP address or MAC address.For the example campaign “Employee Reference Checks”, the source may bea particular employee. In example embodiments, clicking on (i.e.,selecting) the column heading Source 1520 may result in the campaignsbeing sorted by source.

The inventory page 1500 of FIG. 15 may also list the “destination” ofthe personal data associated with a particular campaign under the columnheading Destination 1525. Personal data may be stored in any of avariety of places, for example on one or more storage devices 280 thatare maintained by a particular entity at a particular location.Different custodians may maintain one or more of the different storagedevices. By way of example, referring to FIG. 15, the personal dataassociated with the Internet Usage History campaign 1510 may be storedin a repository located at the Toronto data center, and the repositorymay be controlled by the organization (e.g., Acme corporation) oranother entity, such as a vendor of the organization that has been hiredby the organization to analyze the customer's internet usage history.Alternatively, storage may be with a department within the organization(e.g., its marketing department). In example embodiments, clicking on(i.e., selecting) the column heading Destination 1525 may result in thecampaigns being sorted by destination.

On the inventory page 1500, the Access heading 1530 may show the numberof transfers that the personal data associated with a campaign hasundergone. In example embodiments, clicking on (i.e., selecting) thecolumn heading “Access” 1530 may result in the campaigns being sorted byAccess.

The column with the heading Audit 1535 shows the status of any privacyaudits associated with the campaign. Privacy audits may be pending, inwhich an audit has been initiated but yet to be completed. The auditcolumn may also show for the associated campaign how many days havepassed since a privacy audit was last conducted for that campaign.(e.g., 140 days, 360 days). If no audit for a campaign is currentlyrequired, an “OK” or some other type of indication of compliance (e.g.,a “thumbs up” indicia) may be displayed for that campaign's auditstatus. Campaigns may also be sorted based on their privacy audit statusby selecting or clicking on the Audit heading 1535.

In example inventory page 1500, an indicator under the heading Risk 1540may also display an indicator as to the Risk Level associated with thepersonal data for a particular campaign. As described earlier, a riskassessment may be made for each campaign based on one or more factorsthat may be obtained by the system. The indicator may, for example, be anumerical score (e.g., Risk Level of the campaign), or, as in theexample shown in FIG. 15, it may be arrows that indicate the OverallRisk Assessment for the campaign. The arrows may be of different shades,or different colors (e.g., red arrows indicating “high risk” campaigns,yellow arrows indicating “medium risk” campaigns, and green arrowsindicating “low risk” campaigns). The direction of the arrows—forexample, pointing upward or downward, may also provide a quickindication of Overall Risk Assessment for users viewing the inventorypage 1500. Each campaign may be sorted based on the Risk Levelassociated with the campaign.

The example inventory page 1500 may comprise a filter tool, indicated byFilters 1545, to display only the campaigns having certain informationassociated with them. For example, as shown in FIG. 15, under CollectionPurpose 1550, checking the boxes “Commercial Relations,” “ProvideProducts/Services”, “Understand Needs,” “Develop Business & Ops,” and“Legal Requirement” will result the display under the Data Flow Summary1505 of only the campaigns that meet those selected collection purposerequirements.

From example inventory page 1500, a user may also add a campaign byselecting (i.e., clicking on) Add Data Flow 1555. Once this selectionhas been made, the system initiates a routine to guide the user in aphase-by-phase manner through the process of creating a new campaign(further details herein). An example of the multi-phase GUIs in whichcampaign data associated with the added privacy campaign may be inputand associated with the privacy campaign record is described in FIG.8-13 above.

From the example inventory page 1500, a user may view the informationassociated with each campaign in more depth, or edit the informationassociated with each campaign. To do this, the user may, for example,click on or select the name of the campaign (i.e., click on InternetUsage History 1510). As another example, the user may select a buttondisplayed on screen indicating that the campaign data is editable (e.g.,edit button 1560).

I: FIG. 16: Campaign Information Page and Data Flow Diagram

FIG. 16 shows an example of information associated with each campaignbeing displayed in a campaign information page 1600. Campaigninformation page 1600 may be accessed by selecting (i.e., clicking on),for example, the edit button 1560. In this example, Personal DataCollected section 1605 displays the type of personal data collected fromthe customer for the campaign Internet Usage History. The type ofpersonal data, which may be stored as data elements associated with theInternet Usage History campaign digital record entry. The type ofinformation may include, for example, the customer's Subscriber ID,which may be assigned by the organization (e.g., a customeridentification number, customer account number). The type of informationmay also include data associated with a customer's premises equipment,such as an IP Address, MAC Address, URL History (i.e., websitesvisited), and Data Consumption (i.e., the number of megabytes orgigabytes that the user has download).

Still referring to FIG. 16, the “About this Data Flow” section 1610displays relevant information concerning the campaign, such as thepurpose of the campaign. In this example, a user may see that theInternet Usage History campaign is involved with the tracking ofinternet usage from customers in order to bill appropriately, manageagainst quotas, and run analytics. The user may also see that thebusiness group that is using the sensitive information associated withthis campaign is the Internet group. A user may further see that thenext privacy audit is scheduled for Jun. 10, 2016, and that the lastupdate of the campaign entry was Jan. 2, 2015. The user may also selectthe “view history” hyperlink to display the history of the campaign.

FIG. 16 also depicts an example of a Data Flow Diagram 1615 generated bythe system, based on information provided for the campaign. The DataFlow Diagram 1615 may provide the user with a large amount ofinformation regarding a particular campaign in a single compact visual.In this example, for the campaign Internet Usage History, the user maysee that the source of the personal data is the organization'scustomers. In example embodiments, as illustrated, hovering the cursor(e.g., using a touchpad, or a mouse) over the term “Customers” may causethe system to display the type of sensitive information obtained fromthe respective consumers, which may correspond with the informationdisplayed in the “Personal Data Collected” section 1605.

In various embodiments, the Data Flow Diagram 1615 also displays thedestination of the data collected from the User (in this example, anInternet Usage Database), along with associated parameters related tobackup and deletion. The Data Flow Diagram 1615 may also display to theuser which department(s) and what system(s) have access to the personaldata associated with the campaign. In this example, the Customer SupportDepartment has access to the data, and the Billing System may retrievedata from the Internet Usage Database to carry out that system'soperations. In the Data Flow Diagram 1615, one or more securityindicators may also be displayed. The may include, for example, an “eye”icon to indicate that the data is confidential, a “lock” icon toindicate that the data, and/or a particular flow of data, is encrypted,or an “unlocked lock” icon to indicate that the data, and/or aparticular flow of data, is not encrypted. In the example shown in FIG.16, the dotted arrow lines generally depict respective flows of data andthe locked or unlocked lock symbols indicate whether those data flowsare encrypted or unencrypted.

Campaign information page 1600 may also facilitate communications amongthe various personnel administrating the campaign and the personal dataassociated with it. Collaborators may be added through the Collaboratorsbutton 1625. The system may draw information from, for example, anactive directory system, to access the contact information ofcollaborators.

If comment 1630 is selected, a real-time communication session (e.g., aninstant messaging session) among all (or some) of the collaborators maybe instantiated and overlaid on top of the page 1600. This may behelpful, for example, in facilitating population of a particular page ofdata by multiple users. In example embodiments, the Collaborators 1625and Comments 1630 button may be included on any graphical user interfacedescribed herein, including dialog boxes in which information is enteredor selected. Likewise, any instant messaging session may be overlaid ontop of a webpage or dialog box. The system may also use the contactinformation to send one or more users associated with the campaignperiodic updates, or reminders. For example, if the deadline to finishentering the campaign data associated with a campaign is upcoming inthree days, the business representative of that assigned campaign may besent a message reminding him or her that the deadline is in three days.

Like inventory page 1500, campaign information page 1600 also allows forcampaigns to be sorted based on risk (e.g., Sort by Risk 1635). Thus,for example, a user is able to look at the information for campaignswith the highest risk assessment.

J: FIG. 17: Edit Campaign Dialog

FIG. 17 depicts an example of a dialog box—the edit campaign dialog1000. The edit campaign dialog 1000 may have editable fields associatedwith a campaign. In this example, the information associated with theInternet Usage History campaign 310 may be edited via this dialog. Thisincludes the ability for the user to change the name of the campaign,the campaign's description, the business group, the current owner of thecampaign, and the particular personal data that is associated with thecampaign (e.g., IP address, billing address, credit score, etc.). Inexample embodiments, the edit campaign dialog 1000 may also allow forthe addition of more factors, checkboxes, users, etc.

The system 100 also includes a Historical Record Keeping Module, whereinevery answer, change to answer, as well as assignment/re-assignment ofowners and collaborators is logged for historical record keeping.

Although embodiments above are described in reference to various systemsand methods for creating and managing data flows related to individualprivacy campaigns, it should be understood that various aspects of thesystem described above may be applicable to other privacy-relatedsystems, or to other types of systems, in general. For example, thefunctionality described above for obtaining the answers to variousquestions (e.g., assigning individual questions or sections of questionsto multiple different users, facilitating collaboration between theusers as they complete the questions, automatically reminding users tocomplete their assigned questions, and other aspects of the systems andmethods described above) may be used within the context of PrivacyImpact Assessments (e.g., in having users answer certain questions todetermine whether a certain project complies with an organization'sprivacy policies).

While this specification contains many specific embodiment details,these should not be construed as limitations on the scope of anyinvention or of what may be claimed, but rather as descriptions offeatures that may be specific to particular embodiments of particularinventions. Certain features that are described in this specification inthe context of separate embodiments may also be implemented incombination in a single embodiment. Conversely, various features thatare described in the context of a single embodiment may also beimplemented in multiple embodiments separately or in any suitablesub-combination. Moreover, although features may be described above asacting in certain combinations and even initially claimed as such, oneor more features from a claimed combination may in some cases be excisedfrom the combination, and the claimed combination may be directed to asub-combination or variation of a sub-combination.

Similarly, while operations are depicted in the drawings in a particularorder, this should not be understood as requiring that such operationsbe performed in the particular order shown or in sequential order, orthat all illustrated operations be performed, to achieve desirableresults. In certain circumstances, multitasking and parallel processingmay be advantageous. Moreover, the separation of various systemcomponents in the embodiments described above should not be understoodas requiring such separation in all embodiments, and it should beunderstood that the described program components and systems maygenerally be integrated together in a single software product orpackaged into multiple software products.

Many modifications and other embodiments of the invention will come tomind to one skilled in the art to which this invention pertains havingthe benefit of the teachings presented in the foregoing descriptions andthe associated drawings. While examples discussed above cover the use ofvarious embodiments in the context of operationalizing privacycompliance and assessing risk of privacy campaigns, various embodimentsmay be used in any other suitable context. Therefore, it is to beunderstood that the invention is not to be limited to the specificembodiments disclosed and that modifications and other embodiments areintended to be included within the scope of the appended claims.Although specific terms are employed herein, they are used in a genericand descriptive sense only and not for the purposes of limitation.

What is claimed is:
 1. A computer-implemented data processing method fordetermining a privacy audit schedule for a privacy campaign, the dataprocessing method comprising: displaying, by one or more computerprocessors, on a graphical user interface, a prompt to create anelectronic record for a privacy campaign; receiving, by one or morecomputer processors, a command to create an electronic record for theprivacy campaign; creating, by one or more computer processors, anelectronic record for the privacy campaign and digitally storing therecord; presenting, by one or more computer processors, on one or moregraphical user interfaces, a plurality of prompts for the input ofcampaign data related to the privacy campaign; electronically receiving,by one or more computer processors, campaign data input by one or moreusers, wherein the campaign data relates to: a description of thecampaign; one or more types of personal data obtained as part of thecampaign; a data subject from which the personal data was collected; oneor more storage locations for the personal data; and who is to haveaccess to the personal data; processing, by one or more computerprocessors, the campaign data by electronically associating the campaigndata with the record for the privacy campaign; digitally storing, by oneor more computer processors, the campaign data in association with theelectronic record for the privacy campaign; determining, by one or morecomputer processors, based at least in part on the received campaigndata, a risk value associated with the privacy campaign; and assigning,by one or more computer processors, a privacy audit schedule to theprivacy campaign based on the determined risk value for the privacycampaign.
 2. The computer-implemented data processing method of claim 1,wherein the risk value for the campaign is a numerical risk value forthe campaign.
 3. The computer-implemented data processing method ofclaim 1, wherein the risk value for the campaign is a risk level for thecampaign.
 4. The computer-implemented data processing method of claim 1,wherein the audit schedule is a default audit schedule that has beenpredetermined for the risk value associated with the campaign.
 5. Thecomputer-implemented data processing method of claim 4, wherein thedefault audit schedule has been determined based on one or more privacylaws.
 6. The computer-implemented data processing method of claim 4,wherein the default audit schedule is modifiable by one or more users.7. The computer-implemented data processing method of claim 1, furthercomprising: receiving, by one or more computer processors, a request tomodify the audit schedule assigned to the campaign; and in response toreceiving the request, determining, by one or more computer processors,whether the privacy audit schedule assigned to the privacy campaign ismodifiable.
 8. The computer-implemented data processing method of claim7, further comprising: in response to determining that the auditschedule is modifiable, modifying, by one or more computer processors,the privacy audit schedule for the campaign.
 9. The computer-implementeddata processing method of claim 8, further comprising: in response todetermining that the privacy audit schedule is not modifiable,electronically displaying an indication that the privacy audit scheduleis not modifiable.
 10. The computer-implemented data processing methodof claim 1, further comprising: determining whether a privacy audit, tobe performed according to the privacy audit schedule, is to be performedwithin a threshold period of time from a current time; and in responseto determining that the privacy audit is to be performed within thethreshold period of time from the current time, generating an electronicalert indicating that the privacy audit is to be performed within thethreshold period of time from the current time.
 11. Thecomputer-implemented data processing method of claim 1, furthercomprising: receiving an electronic confirmation that a scheduledprivacy audit, made according to the privacy audit schedule, has beencompleted; and in response to receiving the electronic confirmation,updating the audit schedule to reflect that the scheduled privacy audithas been completed.
 12. The computer-implemented data processing methodof claim 11, wherein the electronic confirmation received is based uponan electronic verification generated if all portions of the scheduledprivacy audit have been verified as completed by one or more users. 13.The computer-implemented data processing method of claim 12, wherein themethod further comprises: receiving documentation related to thecompliance of the privacy campaign; electronically associating thedocumentation received with the record for the campaign with one or moreprivacy regulations; and digitally storing the documentation inassociation with the record for the campaign in an electronic storagedevice.
 14. The computer-implemented data processing method of claim 1,wherein the method further comprises: determining whether the scheduledprivacy audit is overdue based on whether an electronic confirmationthat a scheduled privacy audit, made according to the privacy auditschedule, has been completed; and in response to determining that theprivacy audit is overdue, generating an electronic alert indicating thatthe privacy audit is overdue.
 15. The method of claim 1, wherein themethod further comprises: electronically retrieving the campaign recordand the campaign data associated with the record; and generating, fordisplay, a computer-generated user interface comprising an inventorypage, wherein the inventory page comprises a list of a plurality ofcampaigns and audit information for one or more of the plurality ofcampaigns.
 16. A computer-implemented data processing method fordetermining a privacy audit schedule for a privacy campaign, the dataprocessing method comprising: receiving, by one or more computerprocessors, a command to set up a privacy campaign in privacy managementsoftware; in response to receiving the command, creating, by one or morecomputer processors, an electronic record for the privacy campaign anddigitally storing the record; communicating, by one or more computerprocessors, to one or more users, a plurality of prompts for the inputof campaign data related to the privacy campaign; electronicallyreceiving, by one or more computer processors, campaign data input byone or more users, wherein the campaign data comprises: (1) dataindicating what types of personal data are obtained as part of theprivacy campaign; and (2) data indicating who will have access to thepersonal data; processing, by one or more computer processors, thecampaign data by electronically associating the campaign data with therecord for the privacy campaign; digitally storing, by one or morecomputer processors, the campaign data in association with the recordfor the privacy campaign; determining, by one or more computerprocessors, based at least in part on the received campaign data, a riskvalue associated with the privacy campaign; and assigning, by one ormore computer processors, a privacy audit schedule to the privacycampaign based on the determined risk value for the privacy campaign.17. The computer-implemented data processing method of claim 16, whereinthe risk value for the campaign is a risk level for the campaign. 18.The computer-implemented data processing method of claim 17, wherein theaudit schedule is a default audit schedule that has been predeterminedfor the risk level associated with the campaign.
 19. Thecomputer-implemented data processing method of claim 16, wherein thecampaign data comprises data indicating whether personal data from oneor minors is obtained as part of the privacy campaign.
 20. Thecomputer-implemented data processing method of claim 16, wherein thecampaign data comprises a description of the campaign.
 21. Thecomputer-implemented data processing method of claim 16, wherein thecampaign data comprises one or more storage locations for the personaldata.
 22. A computer-implemented data processing method for determininga privacy audit schedule for a privacy campaign, the data processingmethod comprising: receiving, by one or more computer processors, acommand to set up a privacy campaign in privacy management software; inresponse to receiving the command, creating, by one or more computerprocessors, an electronic record for the privacy campaign and digitallystoring the record; communicating, by one or more computer processors,to one or more users, a plurality of prompts for the input of campaigndata related to the privacy campaign; electronically receiving, by oneor more computer processors, campaign data input by one or more users,wherein the campaign data comprises: (1) data indicating what types ofinformation are obtained as part of the privacy campaign; and (2) dataindicating one or more storage locations for the personal data;processing, by one or more computer processors, the campaign data byelectronically associating the campaign data with the record for theprivacy campaign; digitally storing, by one or more computer processors,the campaign data in association with the record for the privacycampaign; determining, by one or more computer processors, based atleast in part on the received campaign data, a risk value associatedwith the privacy campaign; and assigning, by one or more computerprocessors, a privacy audit schedule to the privacy campaign based onthe determined risk value for the privacy campaign.
 23. Thecomputer-implemented data processing method of claim 22, wherein thecampaign data comprises a description of the campaign.
 24. Thecomputer-implemented data processing method of claim 22, furthercomprising: receiving an electronic confirmation that a scheduledprivacy audit, made according to the privacy audit schedule, has beencompleted; and in response to receiving the electronic confirmation,updating the audit schedule to indicate that the privacy campaign shouldbe audited again by a predetermined date in the future.